Resumen de European Union: Taxation of inter-company dividends in the presence of a PE : the impact of the EC fundamental freedoms (part two)
In this last part of a two-part article the author argues that, with regard to the taxation of inter-company dividends, the European Court of Justice should provide a clearer interpretation of Art. 56 for non-EU scenarios and that action by the Commission and the Council would be desirable in order to extend the scope of the Parent-Subsidiary Directive so that it is in compiance with the fundamental freedoms.
